A federal statute prohibits, for most people, their private possession of a “machinegun.”[1] In Garland v. Cargill, decided on June 14, 2024, the United States Supreme Court ruled that semi-automatic rifles equipped with “bump stock[s]” are not “machinegun[s]” prohibited by that law. The Court meticulously analyzed the technical operation of the inner operations of a “machinegun” as defined by federal law and concluded that a shooter’s manual operation of a “bump stock” equipped semi-automatic rifle does not operate in the same manner. The applicable legal definition of a “machinegun” requires that the gun shoot “automatically more than one shot . . . by a single function of the trigger.”[2] The vote on the Court was 6-3, with Justices Sotomayor, Kagan, and Jackson dissenting.
COMMENT: Justice Thomas’s majority Opinion seemed to meticulously ignore the purpose of the federal statute in the course of interpreting it. The purpose of the statute, enacted during the infamous era of gangsters armed with “Tommy Guns,” was to try to prevent indiscriminate shootings of a lot of people with the use of rapid-fire rifles. Nonetheless, the unambiguous text of written law, such as a statute, should control over a nontextual, and judicial analysis of its purpose. That was the fundamentally democratic principle upon which the Court based its ruling.
Dan Rhea
[1] 18 U.S.C. § 922(o)(1).
[2] 26 U.S.C. § 5845(b).
RECENT RULINGS 